The Aircraft Owners and Pilots Association (AOPA), representing more than 400,000 members nationwide, and 4,600 residing in the State of Alaska, has reviewed Aeronautical Study 04-AAL-14NR Decommissioning of Four Non-Directional Beacons (NDB). The Federal Aviation Administration's (FAA) study fails to clearly articulate the FAA's plan to assist pilots in transitioning from reliance on these NDBs to reliance on other navigation and broadcast weather systems. Before executing this apparent ad-hoc change in the services provided to the users, the FAA's broader transition strategy must be published and coordinated with aviation users.

AOPA members in Alaska operate under both instrument and visual flight rules, and they use NDBs for electronic navigation in conjunction with other navigation tools and to receive crucial weather information. AOPA members also indicate that they use NDBs as a backup navigation system to the Global Positioning System (GPS) receiver they carry on board the aircraft. Members indicate that in Alaska, NDB signals are often receivable when other ground-based navigation aids are not.

AOPA, while strongly supporting a careful and strategic transition to satellite navigation in the National Airspace System, is concerned that the FAA has failed to successfully replace the services afforded by these NDBs before proposing to decommission them.

When developing the transition strategy to satellite navigation, the FAA should also consider the cost to equip aircraft appropriately to match the services available. Our members are concerned about the affordability of new GPS technology. The FAA's Capstone initiative is researching the possibility of providing financial incentive to help aircraft owners expedite the transition, which could reduce the time and cost of supporting today's ground-based navigation systems throughout the state. The strategies envisioned by Capstone should be considered as part of this decommissioning.

AOPA strongly urges the FAA to suspend what appears to be an isolated study and first develop a strategy in coordination with aviation users that accommodates their needs. Decommissioning four NDBs in various parts of the state without such a strategy in place leaves the user community confused and concerned that essential services are being taken away, without fully understanding the necessary actions prior to their removal. If you have any questions, please do not hesitate to contact me at 301/695-2211.